COREDO > NPI Licence in Poland — National Payment Institution

NPI Licence in Poland — National Payment Institution

Poland is one of the leading fintech jurisdictions in Central and Eastern Europe, offering access to the EU market, advanced digital infrastructure, and transparent regulation of payment services. A National Payment Institution (NPI) licence allows companies to provide a full range of payment services and operate throughout the EEA under the passporting regime, without transaction volume limitations.

Since 2016, COREDO has been assisting clients with obtaining NPI licences in Poland, providing full support — from preparing the business model and documentation to liaising with the KNF and securing the licence.

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Cost of the service
from 60 000 EUR

Regulatory Framework

The activities of payment institutions in Poland are regulated at two levels: European and national.

At the EU level, the key instrument is the Payment Services Directive PSD2 (Directive (EU) 2015/2366), which established uniform rules for licensing, prudential supervision, and passporting for payment institutions in all EU member states. PSD2 was transposed into Polish law by the Payment Services Act (Ustawa o usługach płatniczych) of 19 August 2011, with subsequent amendments. The last significant amendment came into force on 29 September 2023.

The national regulator is the Komisja Nadzoru Finansowego (KNF) — the Polish Financial Supervision Authority. KNF makes decisions on the issuance, suspension, and revocation of payment institution licences, maintains a register of payment service providers, and conducts ongoing supervision. Regulator website: knf.gov.pl.

Additionally, companies working with client funds must comply with anti-money laundering (AML) requirements under the Polish AML/CFT Act (Ustawa o przeciwdziałaniu praniu pieniędzy oraz finansowaniu terroryzmu) and the European directives AMLD5 and AMLD6.

Types of Payment Services Under NPI Licence

The NPI licence covers the full range of payment services provided for in Appendix 1 to PSD2.

Holders of an NPI licence have the right to provide the following services:

receipt of deposits and cash withdrawal from payment accounts;

execution of payment transactions (credit transfers, direct debits, card payments);

provision of payment credit;

issuance of payment instruments (cards, mobile wallets, digital vouchers);

acquiring (acceptance of cashless payments from merchants);

money remittance;

payment initiation services (PIS);

account information services (AIS).

Thus, NPI is a universal licence for building a full-fledged digital bank, payment wallet, money transfer service, or B2B payment platform.

Requirements for Obtaining an NPI Licence

The regulator KNF imposes comprehensive requirements on applicants for an NPI licence. They cover several key categories.

Organisational and legal form and location.

The company must be established in Poland in the form of SA (joint-stock company) or Sp. z o.o. (limited liability company), have a registered office and actual head office in Poland.

Minimum own capital.

The size of regulatory capital depends on the list of services provided in accordance with Art. 7 of PSD2: EUR 125,000 — for the full range of payment services (the most common option for NPI); EUR 50,000 — when restricting activities to payment initiation services; EUR 20,000 — when restricting activities to money transfer. If NPI provides payment credit, 5% of the average monthly outstanding balance is added to the base capital.

Management and qualifications.

Members of the board and key managers must have confirmed experience in the financial industry, an unblemished business reputation, and no criminal convictions. KNF assesses each candidate individually. Management requirements were strengthened after 2022: the regulator checks for connections with Russia and Belarus — shareholders and directors must not have documented affiliated relationships with these jurisdictions.

AML/KYC compliance.

The company must appoint an AML officer (MLRO) and develop a comprehensive anti-money laundering policy: procedures for customer identification (KYC), transaction monitoring, identification and reporting of suspicious activity to the financial intelligence unit (GIIF). Policies must comply with Polish AML law and European standards.

IT security and operational resilience.

An IT security officer must be appointed, systems for protection of personal data (GDPR) must be implemented, compliance with PSD2 requirements for strong customer authentication (SCA/3DS) must be ensured. IT infrastructure documentation and a description of the risk management system are submitted to KNF as part of the application.

Business plan and financial planning.

KNF requires a detailed three-year business plan, including financial forecasts (P&L, cash flow), funding model, and description of products and target markets. The regulator specially checks the realism of the business plan and the sustainability of the model.

Protection of client funds.

NPI must segregate client funds from its own (safeguarding) — through a separate bank account or an insurance policy that covers client balances.

Cost of COREDO Services

COREDO offers comprehensive support for obtaining an NPI licence in Poland. The cost of services is determined individually depending on the complexity of the structure and the scope of tasks.

Service	Cost
Obtaining NPI licence in Poland (from scratch)	from EUR 180,000 + VAT
SPI registration + subsequent upgrade to NPI	from EUR 60,000 (SPI) + from EUR 180,000 (upgrade) + VAT

The basic NPI support package includes: registration of a Polish company, preparation of a complete document package for KNF (business plan, AML policies, IT documentation, organisational structure), interaction with the regulator at all stages of application review, support during inspections and requests from KNF, consultation on post-licensing obligations.

Payment Terms

COREDO applies a standard three-stage payment scheme for major licensing projects: 40% advance upon contract signature, 40% upon reaching a key intermediate result (submission of application to KNF), 20% final payment after licence issuance. Exact terms are fixed in the contract and may be adjusted depending on the project’s specifics.

Comparison of NPI with Other Types of Licences in Poland

Poland offers several types of regulatory statuses for fintech companies. The choice of optimal option depends on the scale of activities, planned transaction volume, and geography of operations.

Licence Type	Regulatory Capital	Limits	EEA Passport	Obtaining Timeline	COREDO Price
SPI (Small Payment Institution)	Not required	EUR 1.5 million/month	No	3 months	from EUR 60,000 + VAT
NPI (National Payment Institution)	up to EUR 125,000	Unlimited	Yes	12–24 months	from EUR 180,000 + VAT
EMI (Electronic Money Institution)	EUR 350,000	Unlimited	Yes	18–24 months	—

For companies planning to start activities quickly and with minimal costs, COREDO recommends the “SPI → NPI” strategy: start with the simpler SPI licence (in 3 months), test the product on the Polish market, then upgrade to NPI when reaching transaction limits or needing to operate in other EU countries.

Learn more about the SPI licence: /licences/financial/poland-spi/

Full overview of all financial licences in Poland: /licences/financial/poland/

List of Documents

To submit an NPI licence application to KNF, companies must prepare the following document package:

Corporate and statutory documents: company articles of association, certificate of registration (KRS), confirmation of registered office and real office in Poland, ownership structure disclosing beneficial owners (CRBR register).

Financial planning documents: three-year business plan (including description of business model, target markets, revenue and expense forecasts), financial plan (P&L, balance sheet, cash flow for 3 years), funding model and liquidity management.

Management documents: résumés of board members and key managers, criminal record certificates from all countries of residence, declarations of the absence of affiliated relationships with Russia and Belarus, documents confirming qualifications and experience in the financial field.

AML/CFT documentation: AML policy and KYC procedures (Customer Due Diligence, Enhanced Due Diligence), transaction monitoring procedures and detection of suspicious transactions, Suspicious Activity Reports (SAR) policy, documents on appointment of MLRO/AML officer.

IT and operational documentation: description of IT architecture and security systems, information security policy (ISMS), Business Continuity Planning (BCP) and Disaster Recovery procedures, description of measures for strong customer authentication (SCA) in accordance with PSD2.

Operational policies: internal risk management regulations, procedures for handling customer complaints, safeguarding policy (protection of client funds), procedures for working with agents (if applicable).

Procedure for Obtaining NPI Licence in Poland

Obtaining an NPI licence goes through several sequential stages.

Preliminary preparation (1–3 months).

Registration of a Polish company (Sp. z o.o. or SA), formation of share capital, definition of organisational structure and composition of the board. At this stage, COREDO develops a business plan, AML policies, and IT documentation in accordance with KNF requirements.

01

Forming the application (1–2 months).

Preparation and verification of a complete document package for KNF. The application is submitted to KNF in written form along with all mandatory annexes. COREDO ensures legal correctness and completeness of the application package.

02

KNF review of the application (12–24 months).

After accepting the complete application, the regulator reviews it within the established timeline. According to the European Banking Authority (EBA), Poland historically has one of the longest licensing periods in the EU — from 12 to 24 months. During the process, KNF may send requests for additional information (RFI), each of which suspends the timeline. COREDO ensures prompt interaction with the regulator and prepares responses to requests.

03

Interaction during verification (included in Stage 3).

KNF may organise a meeting with the company’s management, request additional documents, or require changes to the submitted policies. COREDO specialists accompany the client through all communications with the regulator.

04

Licence issuance and registration.

After a positive decision, the company is entered in the register of payment service providers of KNF and receives the status of Krajowa Instytucja Płatnicza. From this moment, the company has the right to immediately begin providing payment services in Poland.

05

EEA Passport (optional, 1–3 months after licence).

To expand operations to other EEA countries, NPI sends a notification to KNF of its intention to operate in a specific country. KNF notifies the host regulator. Typically, this procedure takes 1–3 months.

06

Total: from 14 to 28 months from the start of preparation to licence issuance.

Our Experts

NPI licence projects in Poland at COREDO are managed by specialists since 2016.

Pavel Kos

Head of Legal at COREDO. Has headed the legal direction since July 2020, with COREDO since 2017. Specialises in financial licensing, regulatory law, and deal structuring. Oversees licensing projects in Poland, Czech Republic, Estonia, and other EU jurisdictions.

Basang Ungunov

Lawyer at COREDO. Specialises in financial regulatory law and licensing process support. At COREDO since 2022, participates in preparation of application packages and interaction with regulators.

Frequently Asked Questions

How does NPI differ from SPI in Poland?

The main differences are in scale and geography of operations. SPI is limited to a monthly transaction volume of EUR 1.5 million and operates only in Poland. NPI has no transaction limits and has the right to operate in all EEA countries through the passport mechanism.

Can a foreign citizen get an NPI licence in Poland?

Yes, provided a Polish legal entity is registered. Citizenship itself is not a limiting factor; however, directors and shareholders must not have documented affiliated relationships with Russia and Belarus.

What is the minimum share capital for NPI?

The size of regulatory capital depends on the list of services: from EUR 20,000 (money transfers only) to EUR 125,000 (full range of payment services). This is not the cost of COREDO services, but the mandatory capital of the licensed company itself.

How long does it take to obtain an NPI licence?

The typical timeframe is from 14 to 28 months including preparation. KNF is historically one of the slowest regulators in the EU: according to the EBA 2023 report, the average review period in Poland was 20–24 months.

Can I get SPI first and then upgrade to NPI?

Yes, this is a common strategy. SPI is obtained in 3 months, which allows rapid market entry and product testing. When the EUR 1.5 million/month limit is exceeded or need to operate in other EU countries arises, the company is required to submit an NPI application within 30 days of exceeding the limit.

What is NPI passporting and how does it work?

After obtaining an NPI licence, the company may notify KNF of its intention to operate in another EEA country. KNF sends a notification to the host regulator. This allows NPI to provide payment services in any EU country without a separate national licence — solely on the basis of the Polish licence.

Do I need a real office in Poland?

Yes. KNF requires a registered office and actual head management (head office) in Poland. Companies with formally Polish registration but managed from abroad receive licence denial.

Does COREDO work with clients who don't have a Polish company?

Yes. Registration of a Polish company is included in COREDO’s standard service package. The company’s specialists support the client from the beginning — from establishing a legal entity to obtaining a licence.

Get a Consultation

Ready to begin the process of obtaining an NPI licence in Poland? COREDO specialists have supported financial licensing projects in Poland and throughout Europe since 2016. Contact us for a free initial consultation.